Lewis N. Cotlow v. Commissioner of Internal Revenue
Court of Appeals for the Second Circuit
1Opinion of the Court
WATERMAN, Circuit Judge.
Petitioner is a life insurance agent who has been engaged since 1927 in purchasing from other insurance agents their rights to renewal commissions on life insurance policies. In 1948 he filed his individual return on the cash receipts and disbursements basis. He reported no income on account of assigned renewal commissions that year although he received during the year the total sum of $45,500.70 from assigned commissions on 1,648 policies. Of this amount $23,-563.33 represented receipts over and above the aggregate original cost of the assignments to the petitioner,…
2Cases cited11 opinions
- Lucas v. EarlSupreme Court of the United States · 1930
- Helvering v. HorstSupreme Court of the United States · 1940
- Blair v. CommissionerSupreme Court of the United States · 1937
- Helvering v. EubankSupreme Court of the United States · 1941
- Fairbanks v. United StatesSupreme Court of the United States · 1939
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3Cited by24 opinions
- Leon Stoller and Audrey Stoller v. United StatesCourt of Appeals for the Fifth Circuit · 1971
- Christine L. Pounds as Independent of the Estate of Horace E. Pounds and Christine L. Pounds v. United StatesCourt of Appeals for the Fifth Circuit · 1967
- Ernest L. Wilkinson and Alice L. Wilkinson v. The United StatesUnited States Court of Claims · 1962
- Jones v. CommissionerCourt of Appeals for the Fifth Circuit · 1962
- Hodges v. CommissionerUnited States Tax Court · 1968
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